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Responsibilities of the Radiation Safety Officer

Federal Laws

 

Atomic Energy Act:

The Atomic Energy Act is the fundamental U.S. law on both the civilian and the military uses of nuclear materials. On the civilian side, it provides for both the development and the regulation of the uses of nuclear materials and facilities in the United States, declaring the policy that "the development, use, and control of atomic energy shall be directed so as to promote world peace, improve the general welfare, increase the standard of living, and strengthen free competition in private enterprise." The Act requires that civilian uses of nuclear materials and facilities be licensed, and it empowers the NRC to establish by rule or order, and to enforce, such standards to govern these uses as "the Commission may deem necessary or desirable in order to protect health and safety and minimize danger to life or property." Commission action under the Act must conform to the Act’s procedural requirements, which provide an opportunity for hearings and Federal judicial review in many instances

 

The Nuclear Regulatory Commission (NRC)

10 C.F.R. Chapter 1

Governs the handling, storage, and disposal of radioactive materials.  See the General Statement of Policy and Procedures for NRC Enforcement Actions (July 1995) at Appendix C to 10 C.F.R. Part 2.  This guide is useful for responding to notice of violations.  The training requirements for all individuals who, in the course of employment, are likely to receive an occupation dose in excess of 100 mrem (1 mSv) in a one-year period are set forth at 10 C.F.R. § 19.12.  This law also has reporting requirements (10 C.F.R. § 19.13, § 20.1101 and § 2203) as well as license requirements.

 

NRC Regulations Title 10, Code of Federal Regulations

The U.S. Nuclear Regulatory Commission (NRC) was created as an independent agency by Congress in 1974 to enable the nation to safely use radioactive materials for beneficial civilian purposes while ensuring that people and the environment are protected. The NRC regulates commercial nuclear power plants and other uses of nuclear materials, such as in nuclear medicine, through licensing, inspection and enforcement of its requirements.

 

 

The NRC requires proper recordkeeping and disposal of all radioactive materials. A damaged or broken sign could require an expensive clean up. Schools with these signs are considered a general licensee for NRC purposes and are required to follow these rules:

 

  • must NOT remove the labeling or radioactive symbol, or abandon a sign;
  • must properly dispose of an unused sign (see below);
  • must report to the NRC or the appropriate Agreement State any lost, stolen or broken signs;
  • must inform the NRC or an Agreement State of a name change, change of address or replacement of a general licensee’s designated representative;
  • must NOT give away or sell the sign to another individual, company or institution unless the device is to remain in use at its original intended location; in such a case, the transferor is to notify the recipient of the regulatory requirements and must notify the NRC or Agreement State of the transfer within 30 days.

Tritium EXIT signs must NOT be disposed of as normal trash. To dispose of a sign properly, a general licensee must transfer the sign to a specific licensee. This would typically be a manufacturer, distributor, licensed radioactive waste broker, or a licensed low-level radioactive waste disposal facility. These facilities may charge a fee for this service.

           Within 30 days of disposing of a sign, the general licensee is required to file a report to the NRC or Agreement State that includes:

  • the device manufacturer’s (or distributor’s) name, model number and serial number;
  • the name, address, and license number of the person receiving the device; and
  • the date of the transfer.

           Reports should be sent to Director, Office of Federal and State Materials and Environmental Management Programs, ATTN: GLTS, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001.

The RSO is responsible for ensuring compliance with care and disposal of Radioactive exit signs, and for ensuring any reporting and record keeping. See January 2009 NRC Fact Sheet on Radiocative Exit Signs.

 

NRC, 10 CFR 70, Domestic Licensing of Special Nuclear Material

Task:

License # SNM-164 - Maintain the license that authorizes univeristy to receive title to, own, acquire, deliver, receive, possess, use, or transfer special nuclear material.

Date last renewed/submitted: 5/6/02
Next due date: 5/31/12

 

NRC, 10 CFR 40, Domestic Licensing of Source Material

Task:

License # SUD-157 - Maintain the license that authorizes the university to receive title to, own, receive, possess, use, transfer, deliver or dispose of byproduct material or residual radioactive material as defined in this part or any source material after removal from its place of deposit in nature.

Date last renewed/submitted: 7/14/03
Next due date: 7/31/13

 

NRC, 10 CFR 30, Rules of General Applicability to Domestic Licensing of Byproduct Material

Task:

License # 08-02075-03 - Maintain the license that authorizes the university to manufacture, produce, transfer, receive, acquire, own, possess, or use byproduct material.

 

Date last renewed/submitted: 7/9/04
Next due date: 7/31/15

 

NRC, 10 CFR 30.35(e), Financial Assurance and Recordkeeping for Decommissioning

Task:

Cost estimate for decommissioning and financial assurance report - Develop a decommissioning funding plan that contains a cost estsimate for decommissioning and a description of the method of assuring funds for decommissioning. Cost estimates must be adjusted at intervals not to exceed 3 years. The decommissioning funding plan must also contain a certification by the licensee that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning and a signed original of the financial instrument obtained.

 

Date last renewed/submitted: 5/31/07
Next due date: 3/01/10

 

NRC 10, CFR 19.13, Notifications and Reports to Individuals

Task:

Individual Radiation Dosimetry Reports - Annually advise each individual monitored of the dose received in that monitoring year if:

(1) The individual’s occupational dose exceeds 1 mSv (100 mrem) TEDE or 1 mSv (100 mrem) to any individual organ or tissue

(2) The individual requests his or her annual dose report

Date last renewed/submitted: 3/31/09
Next due date: 3/31/10

 

 

NRC, 10 CFR 40.64, Reports

Task:

Material Balance reports – NMMSS program (License # SUD-157) - Send Material Balance Reports semi-annually to NRC that documents the nuclear material balances of all nuclear material on campus.

 

Date last renewed/submitted: 3/31/04
Next due date: None until future receipts

 

NRC, 10 CFR 74.13, Material Status Reports

Task:

Material Balance reports – NMMSS program (License # SNM-164) - Send Material Balance Reports semi-annually to NRC that documents special nuclear material that the licensee has received, produced, possessed, transferred, consumed, disposed of, or lost.  The Physical Inventory Listing Report must be submitted with each Material Balance Report.

 

Date last renewed/submitted: 3/31/04
Next due date: None until future receipts

 

NRC, 10 CFR 19, Notices, Instructions and Reports to Workers: Inspection and Investigations

Task:

Radiation Safety Training - Provide radiation safety training to all employees who in the course of employment are likely to receive in a year an occupational dose in excess of 100 mrem (1 mSv).  This training should include such information as: the health protection problems associated with exposure to radiation and/or radioactive material, precautions or procedures to minimize exposure, and the purposes and functions of protective devices employed; the applicable provisions of NRC regulations and licenses for protection from exposure to radiation and/or radioactive material; their responsibility to report promptly to the university any condition which may lead to or cause a violation of NRC regulations and licenses or unnecessary exposure to radiation and/or radioactive material; and the appropriate response to warnings made in the event of any unusual occurrence or malfunction that may involve exposure to radiation and/or radioactive material.

 

Date last renewed/submitted: 10/9/08
Next due date: As needed

 

NRC, 10 CFR 20.1101, Radiation Protection Programs

Task:

Review Radiation Protection Program Content and Implementation - Annually review the radiation protection program content and implementation.

 

Date last renewed/submitted: 12/15/08
Next due date: 12/15/09

 

 

NRC License Conditions:

Tasks:

Meter Calibration (annual)

 

Date last renewed/submitted: 9/1/09
Next due date: 9/1/10

 

Source Inventory (semi-annual)

 

Date last renewed/submitted: 5/21/09

Next due date: 11/21/09

 

Sealed Source Leak Test (semi-annunal)

 

Date last renewed/submitted: 5/21/08
Next due date: 11/21/09

 

Film Badge Changeout (quarterly)

 

Date last renewed/submitted: 6/30/08

Next due date: 9/30/09

 


 

D.C. Laws:

 

D.C. Department of Health, 20 DCMR 2235.1

Task:

Possession of Radioactive Materials Fee - Pay a $500 fee to the D.C. Department of Health.

 

Date last renewed/submitted: 9/30/07
Next due date: D.C. Suspended Fee

 

D.C. Department of Health, 20 DCMR 2120.1

Task:

LLRW Generator Fee - Each year, pay to the D.C. Treasurer a $5,000 fee to register the university’s Low-Level Radioactive Waste (LLRW) generator.

 

Date last renewed/submitted: 9/20/06
Next due date: D.C. Suspended Fee


D.C. Department of Health, 22 DCMR
Task:
X-Ray Registration FeeEvery 2 years, pay to the D.C. Treasurer a $125 fee to register the university’s X-Ray Machines.

Date last renewed/submitted: 9/10/09
Next due date: 9/30/11

D.C. Department of Health, 22 DCMR
Task:
X-Ray Inspector FeeEach year, pay to the D.C. Treasurer a $100 fee to renew the university’s X-Ray Inspector License.

Date last renewed/submitted: 9/10/09
Next due date: 9/30/10

 


Other laws:

 

South Carolina DHEC, Regulation 61-83, Transportation of Radioactive Waste Into or Within South Carolina
Task:

S.C. Radioactive Waste Transportation Permit Fee - Maintain the radioactive waste transport permit by paying the $200 fee each year to the South Carolina Department of Health and Environmental Control.  Permits are valid from the date of issuance through December 31 of each calendar year.

 

Date last renewed/submitted: 12/20/06
Next due date: Permit is no longer in use. This facility is no longer accepting waste from the District of Columbia

 


Resources: 

 

MIT Environmental Virtual Campus website provides EHS departments with campus environmental management practices, including both regulatory compliance and non-regulatory "green" environmental practices.  Especially relevant is the information regarding mixed waste.

 

U.S. Department of Energy's Office of Civilian Radioactive Waste Management's website provides information about program management, the Yucca Mountain Project, scientific and technological improvements, and development of waste acceptance, storage and transportation programs. 

 

U.S. Nuclear Regulatory Commission’s website offers useful information regarding radioactive waste. 

 

Related Policies

Environmental Health & Safety


updated 8-13-09 by JP to add policies



Last Revised 15-Sep-09 09:11 AM.